The UK’s Digital Product Record Call for Evidence and the EU’s Digital Product Passport – what should businesses be doing now?

On 27 July 2026, the UK Government launched a call for evidence to gather business’ views on the implementation of Digital Product Records.

This call for evidence follows the EU’s introduction of Digital Product Passports  (“DPP”) established under the Ecodesign for Sustainable Products Regulation (EU) 2024/1781 (ESPR).

With the first of the EU’s mandatory EU Digital Product Passport requirements entering into force for Batteries and Construction Products in 2027, the UK Government has decided that now is an important moment to explore the UK’s approach to implementation of Digital Product Records.

Digital product record systems, such as the EU Digital Product Passports, are intended to store product information in a way that is easily accessible to those who need it. They look set to form an increasingly significant component of the regulatory landscape for goods across the globe and, in the UK Government’s own words, have the potential to streamline administrative processes for businesses, and facilitate improved transparency for consumers, with respect to product information and sustainability.

The EU’s Approach

The Ecodesign for Sustainable Products Regulation 2024/1781 (ESPR) entered into force in July 2024.

ESPR mandates that certain products on the EU and Northern Ireland market should carry an EU DPP – a digital record of environmental and sustainability information – which is to be updated throughout a product’s lifecycle. The aim behind the DPPs are to promote traceability , transparency and accessibility to products, enable sustainable circular business models and assist with better enforcement in relation to non-compliant products and product safety.

At present, the data intended to be accessible via EU DPPs includes information relating to a product’s manufacturing location, materials, environmental impact, repairability and recyclability although the precise information included will vary depending on the applicable EU legislation and product category. The DPP will be accessed by scanning a data carrier (such as a QR code) placed on the product, its packaging or accompanying documentation. The obligations required for DPPs will therefore fall on a full range of a products supply chain and is a real business opportunity. By improving transparency and traceability, DPP’s may support better supply chain performance, increase efficiency, quality and compliance and help digitalise data exchange between companies.

EU DPP requirements will be implemented in a phased roll-out, beginning with batteries in February 2027 (under the EU’s Batteries Regulation 2023/1542 (EUBR)).

Current Position in the UK

The UK Government has not yet determined its approach to Digital Product Records and the call for evidence is predominantly focused on the merits of introducing Digital Product Records and the range of options linked to the digitalisation of product information - including the Product Safety framework consultation that ran until 26 June 2026 and the associated “digital by default” approach to product information labelling.

However, note that EU DPP requirements will apply under the Windsor Framework, maintaining Northern Ireland’s access to both the EU and UK markets.

Key considerations for Businesses

For companies operating in the EU and Northern Irish markets, preparation for the EU Digital Product Passports requirements should already be underway. If not, and as a starting point, those businesses should identify which, if any, of the EU DPP requirements will apply to their products and take note of key implementation deadlines.

The UK Government’s recent call for evidence raises the question for companies operating in both markets on whether steps that have been taken to ensure compliance with the EU could in fact assist with any eventual UK requirements. Certainly, it is clearly that change is on the horizon but whether that change will result in a wider divergence with the EU or alignment is unclear. One aspect of the Call for Evidence is to seek views on the impacts businesses would face if the EU and UK have different rules governing digital product records/passports and the potential of an associated duel compliance burden.

With this in mind, UK companies should consider:

1. Engaging with the UK Government’s request for information with a view to shaping the outcome
2. Existing product information and whether this will be sufficient for future information requirements – reviewing the EU’s requirements will assist with this;
3. Establishing product compliance records across supply chains in anticipation of these changes.

In the event that support is required for businesses with any aspect of this article or any issues arising from product safety or product liability claims more generally, please contact Clyde & Co's Product Liability, Safety and Recall Team led by Partners, Peter Barnes and Charlotte Kelly.